Overlay · not the system of recordHolds sit above scoreAsk Desk is deterministic — no modelLocal

GRC / regulatory analyst

State UDAAP class language on collections letters

MA 93A / collections

Lane · Standard

PriorityP3

Severitymoderate

PacketReady

Suggested—

Why this is here

Plaintiff firm letter cites our 2024 collections template. Letter is not a rule, but the template is still live.

LegalDemand letter received yesterday
TemplateCOL-22 still in production
OpenPagesNo issue opened yet

Recommended. Monitor the litigation. Spot-check whether the cited sentence is still in production.

This may be a demand letter, not a regulatory action. Treating it as an OCC MRIA would be wrong.

Current: Open

Overlay only. Will POST a label to the write-back URL, never a funds release. IBM OpenPages OPSS-Iss:WorkflowStatus=WATCH on reg-state-udaap. Desk is not the system of record.